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  • Posts by Kristen S. Lowther
    Senior Counsel
    | 404.588.3432

    Kristen Lowther specializes in the area of tax controversy and tax planning. Her practice spans a wide array of tax matters, focusing primarily on helping individuals, partners/partnerships, and corporations to successfully ...

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Members of Tax Controversy & Litigation Practice File Comments on Proposed Employee Retention Credits Regulations
Posted August 19, 2024 by Larry A. Campagna, Tom Cullinan, John W. Hackney, Philip Karter, Samuel T. Kuzniewski, Kristen S. Lowther, Charles Rettig, Kevin F. Sweeney, Leo Unzeitig, Jaime Vasquez, Victor J. Viser

Members of our Tax Controversy & Litigation practice filed comments last week on the proposed regulations published July 2, 2024, regarding the Employee Retention Credits. They argued that these proposed regulations exceed the IRS and Treasury authority. They also urged these bodies to abandon the current proposed regulations as they relate to the ERC, and to reconsider the appropriateness of the final regulations treating excessive ERC refunds as underpayments of tax, particularly in light of the Supreme Court's recent decision in Loper Bright Enterprises v. Raimondo. 

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